TAX CONVENTIONS

Notice 2008–3, page 253. On January 1, 2008, the impuesto empresarial a tasa única (IETU), a single rate business tax adopted by Mexico, will become effective. This notice provides that, pending the outcome of a study to determine whether the IETU is a creditable income tax, the IRS will not challenge a taxpayer’s position that the IETU is an income tax that is eligible for a credit under Article 24(1) of the U.S.-Mexico income tax treaty.